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The View from the Bench and Chambers: Examining Judicial Process and Decision Making on the U.S. Courts of Appeals (Constitutionalism and Democracy)
by Jennifer Barnes Bowie Donald R. Songer John SzmerFor most of their history, the U. S. courts of appeals have toiled in obscurity, well out of the limelight of political controversy. But as the number of appeals has increased dramatically, while the number of cases heard by the Supreme Court has remained the same, the courts of appeals have become the court of last resort for the vast majority of litigants. This enhanced status has been recognized by important political actors, and as a result, appointments to the courts of appeals have become more and more contentious since the 1990s. This combination of increasing political salience and increasing political controversy has led to the rise of serious empirical studies of the role of the courts of appeals in our legal and political system. At once building on and contributing to this wave of scholarship, The View from the Bench and Chambers melds a series of quantitative analyses of judicial decisions with the perspectives gained from in-depth interviews with the judges and their law clerks. This multifaceted approach yields a level of insight beyond that provided by any previous work on appellate courts in the United States, making The View from the Bench and Chambers the most comprehensive and rich account of the operation of these courts to date.
The View From the Corner Shop: The Diary of a Yorkshire Shop Assistant in Wartime
by Kathleen HeyKathleen Hey spent the war years helping her sister and brother-in-law run a grocery shop in the Yorkshire town of Dewsbury. From July 1941 to July 1946 she kept a diary for the Mass-Observation project, recording the thoughts and concerns of the people who used the shop. What makes Kathleen's account such a vivid and compelling read is the immediacy of her writing. People were pulling together on the surface ('Bert has painted the V-sign on the shop door…', she writes) but there are plenty of tensions underneath. The shortage of food and the extreme difficulty of obtaining it is a constant thread, which dominates conversation in the town, more so even than the danger of bombardment and the war itself. Sometimes events take a comic turn. A lack of onions provokes outrage among her customers, and Kathleen writes, 'I believe they think we have secret onion orgies at night and use them all up. ' The Brooke Bond tea rep complains that tea need not be rationed at all if supply ships were not filled with 'useless goods' such as Corn Flakes, and there is a long-running saga about the non-arrival of Smedley's peas. Among the chorus of voices she brings us, Kathleen herself shines through as a strong and engaging woman who refuses to give in to doubts or misery and who maintains her keen sense of humour even under the most trying conditions. A vibrant addition to our records of the Second World War, the power of her diary lies in its juxtaposition of the everyday and the extraordinary, the homely and the universal, small town life and the wartime upheavals of a nation.
A View from the Eye of the Storm: Terror and Reason in the Middle East
by Haim HarariIn 2004, internationally known physicist Haim Harari was invited to address the advisory board of a major multinational corporation. In a short speech he offered a penetrating analysis of the components of terror, and presented a passionate call for a new era in the Middle East. The speech, entitled "A View from the Eye of the Storm," was not intended for publication, but when a copy was leaked and posted onto the Internet, it caused a worldwide sensation, eventually being translated into more than half a dozen languages. Now—as the modern era of Islamic terror continues to unfold—Harari reaches further, to offer this serious yet accessible survey of the landscape of Middle Eastern war and peace at this challenging crossroads in history.Moving beyond the sterile discourse of foreign affairs journals, Harari encourages the world to view the Middle East through the eyes of a "proverbial taxi driver," a man on the street whose wisdom (and sense of humor) outstrips that of the experts. And, as he observes, to anyone familiar with the Middle East from a taxi driver's perspective, the "persistent ugly storm" engulfing the Arab world is far more than a territorial battle with Israel: It is an "undeclared World War III" that rages from Bali to Madrid, from Nairobi to New York, from Buenos Aires to Istanbul, and from Tunis to Moscow. The sad result is that much of the Arab world has become an "unprecedented breeding ground for cruel dictators, terror networks, fanaticism, incitement, suicide murders, and general decline." And unless the free nations of the world mobilize to stop it, Harari argues, this new world war will continue to cause bloodshed on all continents.As a fifth-generation Israeli-born observer, Harari includes a thorough response to the conventional wisdom about Middle Eastern affairs, including a frank dissection of the media's lopsided portrait of the Arab-Israeli conflict. Drawing on his family's two centuries of life in the Middle East, he offers a compelling catalog of the steps necessary to reach a lasting peace between Israel and the Palestinians—steps, he writes, that are "inevitable—not because everybody accepts them today, but because all sides must accept them before peace can be achieved." And he urges the civilized world to combat terror by isolating its state sponsors, blocking its funding, and promoting education, women's equality, and human rights reform.Eloquent in its simplicity, written with passion, humor, and the directness of a scientist who has spent a lifetime explaining his work to the general public, A View from the Eye of the Storm is that rare book with the power to change hearts and minds.
A View from the Stands
by John Kenneth GalbraithIn the decades since World War II, no American writer has done more to comfort the afflicted and afflict the comfortable than John Kenneth Galbraith. Galbraith reflects on many famous people, including Mencken, Hemingway, O'Hara, Muggeridge, Buckley, and more.
The View From The Tower
by Charles LambertComparable to The Girl Who Fell From the Sky by Simon Mawer and Ordinary Thunderstorms by William Boyd. Media and online promotion, including advertisements online and in print, and promoted through our street team of bloggers and reviewers, the Witness Protection Program. Physical ARCS available, and digital ARCs issued through NetGalley. Co-promotion with The Friday Project at HarperCollins, who will be publishing a non-fiction title by the author at the same time.
A View of the State of Ireland
by Andrew Hadfield Willy Maley Edmund SpenserA translation which maintains much of the spelling of the time.
Viewers Like You: How Public TV Failed the People
by Laurie OuelletteHow "public" is public television if only a small percentage of the American people tune in on a regular basis? When public television addresses "viewers like you," just who are you? Despite the current of frustration with commercial television that runs through American life, most TV viewers bypass the redemptive "oasis of the wasteland" represented by PBS and turn to the sitcoms, soap operas, music videos, game shows, weekly dramas, and popular news programs produced by the culture industries. Viewers Like You? traces the history of public broadcasting in the United States, questions its priorities, and argues that public TV's tendency to reject popular culture has undermined its capacity to serve the people it claims to represent. Drawing from archival research and cultural theory, the book shows that public television's perception of what the public needs is constrained by unquestioned cultural assumptions rooted in the politics of class, gender, and race.
Viewing Velocities: Time in Contemporary Art
by Marcus VerhagenContemporary art and the culture of speedHow have artists responded to our market-driven, tech-enabled culture of speed? Viewing Velocities explores a contemporary art scene caught in the gears of 24/7 capitalism. It looks at artists who embrace the high-octane experience economy and others who are closer to the slow movement. Some of the most compelling artworks addressing the cadences of contemporary work and leisure play on distinct, even contradictory conceptions of time. From Danh Vo's relics to Moyra Davey's photographs of dust-covered belongings, from Roman Ondak's queuing performers and Susan Hiller's outdoor sleepers to Maria Eichhorn's art strike and Ruth Ewan's giant reconstruction of the French revolutionary calendar, artists have drawn out aspects of the present temporal order that are familiar to the point of near-invisibility, while outlining other, more liberating ways of conceiving, organising and experiencing time.Marcus Verhagen builds on the work of theorists Jonathan Crary, Hartmut Rosa and Jacques Rancière to trace lines of insurgent art that recast struggles over time and history in novel and revealing terms.
Vigilance
by Robert Jackson BennettRobert Jackson Bennett's Vigilance is a dark science fiction action parable from an America that has permanently surrendered to gun violence.The United States. 2030. John McDean executive produces "Vigilance," a reality game show designed to make sure American citizens stay alert to foreign and domestic threats. Shooters are introduced into a "game environment," and the survivors get a cash prize.The TV audience is not the only one that's watching though, and McDean soon finds out what it's like to be on the other side of the camera.At the Publisher's request, this title is being sold without Digital Rights Management Software (DRM) applied.
Vigilance: My Life Serving America and Protecting Its Empire City
by Ray KellyTwo-time New York City police commissioner Ray Kelly opens up about his remarkable life, taking us inside fifty years of law enforcement leadership, offering chilling stories of terrorist plots after 9/11, and sharing his candid insights into the challenges and controversies cops face today. The son of a milkman and a Macy's dressing room checker, Ray Kelly grew up on New York City's Upper West Side, a middle-class neighborhood where Irish and Puerto Rican kids played stickball and tussled in the streets. He entered the police academy and served as a marine in Vietnam, living and fighting by the values that would carry him through a half century of leadership-justice, decisiveness, integrity, courage, and loyalty. Kelly soared through the NYPD ranks in decades marked by poverty, drugs, civil unrest, and a murder rate that, at its peak, spiked to over two thousand per year. Kelly came to be known as a tough leader, a fixer who could go into a troubled precinct and clean it up. That reputation catapulted him into his first stint as commissioner, under Mayor David Dinkins, where Kelly oversaw the police response to the 1993 World Trade Center bombing and spearheaded programs that would help usher in the city's historic drop in crime. Eight years later, in the chaotic wake of the 9/11 attacks, newly elected mayor Michael Bloomberg tapped Kelly to be NYC's top cop once again. After a decade working with Interpol, serving as undersecretary of the Treasury for enforcement, overseeing U.S. Customs, and commanding an international police force in Haiti, Kelly understood that New York's security was synonymous with our national security. Believing that the city could not afford to rely solely on "the feds," he succeeded in transforming the NYPD from a traditional police department into a resource-rich counterterrorism-and-intelligence force. In this vital memoir, Kelly reveals the inside stories of his life in the hot seat of "the capital of the world"-from the terror plots that nearly brought a city to its knees to his dealings with politicians, including Presidents Bill Clinton, George W. Bush, and Barack Obama as well as Mayors Rudolph Giuliani, Bloomberg, and Bill DeBlasio. He addresses criticisms and controversies like the so-called stop-question-and-frisk program and the rebuilding of the World Trade Center and offers his insights into the challenges that have recently consumed our nation's police forces, even as the need for vigilance remains as acute as ever.
Vigilance Is Not Enough: A History of United States Intelligence
by Mark M. LowenthalA broad and deep survey of American intelligence from before the Revolution to the present Every nation has an intelligence apparatus—some means by which its top officials acquire needed information on sensitive issues. But each nation does it differently, influenced by its history, its geographical conditions, and its political traditions. In this book, Mark M. Lowenthal examines the development of U.S. intelligence to explain how and why the United States went from having no intelligence service to speak of to being the world&’s predominant intelligence power almost overnight, and he discusses the difficult choices involved in maintaining that dominance in a liberal democracy. Lowenthal describes how the lack of a tradition of spycraft both hindered and helped American efforts to develop intelligence services during and after the Second World War. He points to the political pragmatism—leading to difficult choices—with which most intelligence directors operated; the constant tension between security and civil liberties in a constitutional democracy; the tension between the need for secrecy and the accountability required for democratic governance; and the way the growing importance of technology changed both the methods and the objectives of intelligence gathering. Far more than simply an episodic history, this book offers an analysis of why American intelligence developed as it did—and what it has meant for the nation&’s and the world&’s politics.
A Vigilant Society: Jewish Thought and the State in Medieval Spain
by Javier RoizA Vigilant Society presents a provocative hypothesis that argues that Western society as we know it emerged from the soil of Jewish intellectual advances in the thirteenth century, especially those formulated on the Iberian Peninsula. A paradigmatic shift began to occur, one that abandoned the pre–Gothic Sephardic wisdom found in, for example, the writings of Maimonides in favor of what author Javier Roiz calls the "vigilant society." This model embraces a conception of politics that includes a radical privatization of an individual's interior life and—especially as adopted and adapted in later centuries by Roman Catholic and Calvinist thinkers—is marked by a style of politics that accepts the dominance of power and control as given. Vigilant society laid the foundation for the Western understanding of politics and its institutions and remains pervasive in today's world.
The Vigilant Spy (A Yuri Kirov Thriller #4)
by Jeffrey LaytonOnce a spy . . . Granted asylum by the United States, former Russian naval intelligence officer Yuri Kirov wants nothing more than to live peacefully with his adopted American family. But first the underwater technology expert must pay a price . . . Yuri is drafted by the CIA. His mission: assist U.S. spies with uncovering the secret behind the People&’s Republic of China&’s new weapon system, codename SERPENT. The radical antisubmarine technology erases America&’s advantage in underseas warfare. Amid the turmoil of escalating tension between China and Russia, Yuri&’s team is inserted by a spy sub onto Hainan Island in the South China Sea. The mission spirals out of control, leaving Yuri trapped with a CIA officer and a beautiful, high-ranking Chinese engineer. With PRC forces closing in and war between superpowers about to break out, there is only one avenue of escape left. That route will pit Yuri against China&’s full might and power . . . Praise for the The Good Spy &“An explosive, high-stakes thriller that keeps you guessing.&” —Leo J. Maloney &“The excitement never stops . . . high adventure at its very best.&”—Gayle Lynds &“A page-turner with as much heart as brains.&” —Dana Haynes &“A fast-paced adventure that will take readers on a thrilling journey.&” —Diana Chambers &“Breathless entertainment.&” —Tim Tigner
The Vigilant Spy (A Yuri Kirov Thriller #4)
by Jeffrey LaytonOnce a spy . . . Granted asylum by the United States, former Russian naval intelligence officer Yuri Kirov wants nothing more than to live peacefully with his adopted American family. But first the underwater technology expert must pay a price . . . Yuri is drafted by the CIA. His mission: assist U.S. spies with uncovering the secret behind the People&’s Republic of China&’s new weapon system, codename SERPENT. The radical antisubmarine technology erases America&’s advantage in underseas warfare. Amid the turmoil of escalating tension between China and Russia, Yuri&’s team is inserted by a spy sub onto Hainan Island in the South China Sea. The mission spirals out of control, leaving Yuri trapped with a CIA officer and a beautiful, high-ranking Chinese engineer. With PRC forces closing in and war between superpowers about to break out, there is only one avenue of escape left. That route will pit Yuri against China&’s full might and power . . . Praise for the The Good Spy &“An explosive, high-stakes thriller that keeps you guessing.&” —Leo J. Maloney &“The excitement never stops . . . high adventure at its very best.&”—Gayle Lynds &“A page-turner with as much heart as brains.&” —Dana Haynes &“A fast-paced adventure that will take readers on a thrilling journey.&” —Diana Chambers &“Breathless entertainment.&” —Tim Tigner
Vigilante Nation: How State-Sponsored Terror Threatens Our Democracy
by Jon Michaels David NollFor readers of How Democracies Die, two legal scholars expose the MAGA Republican strategy to roll back civil, political, and privacy rights and subvert American democracy—and prescribe a plan for beating the Christian nationalists at their own game.Time and again, when confronted with serious challenges to their power and privilege, white Christian nationalists seek solace—and satisfaction—in state-supported forms of vigilantism. This was true at the dawn of the American republic, when Northern abolitionists threatened the Southern slavocracy. It was also true in the aftermath of the Civil War, when emancipated Black Americans and their Northern allies sought to fulfill the promises of Reconstruction. And though this pattern was seemingly broken after the Civil Rights revolution of the 1950s and &’60s—and abandoned once and for all—legal vigilantism has made a surprising, roaring comeback in the months and years following the failed coup of January 6, 2021. Committed to never again losing power, let alone experiencing the humiliation that followed on the heels of the ham-fisted insurrection, overlapping networks of right-wing lawyers, politicians, plutocrats, and preachers have resurrected state-supported vigilantism. Vigilante Nation tells this story of the American Right marginalizing, subordinating, and disenfranchising the increasingly diverse and cosmopolitan members of the American polity. This book exposes the vigilantes&’ plans, explains their methods—everything from book bans to anti-abortion bounties to attacks on government proceedings, including elections—and underscores the stakes. Now that supporters of democratic equality are numerous and dexterous enough to finally secure the broad promises of the civil rights revolution, the race is on for Donald Trump, J.D. Vance, and the architects of Project 2025 to subvert our democracy before a countermovement can rise up to thwart their insidious plans.
Vigilantes beyond Borders: NGOs as Enforcers of International Law
by Mette Eilstrup-Sangiovanni J C SharmanHow and why NGOs are increasingly taking independent and direct action in global law enforcement, from human rights to the environment Nongovernmental organizations (NGOs) have generally served as advocates and service providers, leaving enforcement to states. Now, NGOs are increasingly acting as private police, prosecutors, and intelligence agencies in enforcing international law. NGOs today can be found investigating and gathering evidence; suing and prosecuting governments, companies, and individuals; and even catching lawbreakers red-handed. Examining this trend, Vigilantes beyond Borders considers why some transnational groups have opted to become enforcers of international law regarding such issues as human rights, the environment, and corruption, while others have not.Three factors explain the rise of vigilante enforcement: demand, supply, and competition. Governments commit to more international laws, but do a poor job of policing them, leaving a gap and creating demand. Legal and technological changes make it easier for nonstate actors to supply enforcement, as in the instances of NGOs that have standing to use domestic and international courts, or smaller NGOs that employ satellite imagery, big data analysis, and forensic computing. As the growing number of NGOs vie for limited funding and media attention, smaller, more marginal, groups often adopt radical strategies like enforcement.Looking at the workings of major organizations, including Amnesty International, Greenpeace, and Transparency International, as well as smaller players, such as Global Witness, the Sea Shepherd Conservation Society, and Bellingcat, Vigilantes beyond Borders explores the causes and consequences of a novel, provocative approach to global governance.
Vigilantism against Migrants and Minorities (Routledge Studies in Fascism and the Far Right)
by Tore Bjørgo Miroslav MaresThis edited volume traces the rise of far right vigilante movements – some who have been involved in serious violence against minorities, migrants and other vulnerable groups in society, whereas other vigilantes are intimidating but avoid using violence. Written by an international team of contributors, the book features case studies from Western Europe, Eastern Europe, North America, and Asia. Each chapter is written to a common research template examining the national social and political context, the purpose of the vigilante group, how it is organised and operates, its communications and social media strategy and its relationship to mainstream social actors and institutions, and to similar groups in other countries. The final comparative chapter explores some of the broader research issues such as under which conditions such vigiliantism emerges, flourishes or fails, policing approaches, masculinity, the role of social media, responses from the state and civil society, and the evidence of transnational co-operation or inspiration. This is a groundbreaking volume which will be of particular interest to scholars with an interest in the extreme right, social movements, political violence, policing and criminology.
Vignettes & Vino: Dinner Table Stories from the Trump White House with Recipes & Cocktail Pairings
by Brian Morgenstern Teresa MorgensternThese are true, human, lighthearted, and significant moments from the most high-stakes environment on Earth, the White House—written by two people who found love at the intersection of politics, a global pandemic, civil strife, an unexpected Supreme Court confirmation, and a heated presidential election—presented with comfort food recipes and cocktail pairings.This book is full of aspirational, surprising, funny, and interesting stories from insiders who were there at the highest levels of government during the election and pandemic of 2020. The stories are combined with themed, practical recipes and cocktails for lovers of American history. Vignettes & Vino is a one-stop handbook for your next dinner party!
Viking Boorish, King of England
by Jorge Alberto Campos García Borja Loma BarrieHistorical novel. Biography. William of Normandy and his acces to power. The humiliation by his condition of bastard. Revenge on those who offended and humiliated him. History of the Vikings. How and why they settled in Normandy before the impotence of the king of France. The Vikings in England. The assault of William to England and his coronation in Westminster.
Viking Economics: How the Scandinavians Got It Right-and How We Can, Too
by George LakeyLiberals worldwide invoke Scandinavia as a promised land of equality, while most conservatives fear it as a hotbed of liberty-threatening socialism. But the left and right can usually agree on one thing: that the Nordic system is impossible to replicate elsewhere. The US and UK are too big, or too individualistic, or too . . . something. In Viking Economics--perhaps the most fun economics book you've ever read--George Lakey dispels these myths. He explores the inner-workings of the Nordic economies that boast the world's happiest, most productive workers, and explains how, if we can enact some of the changes the Scandinavians fought for surprisingly recently, we, too, can embrace equality in our economic policy.
Vilfredo Pareto: The Illusions and Disillusions of Liberty (1891–1898) (Palgrave Studies in the History of Economic Thought)
by Fiorenzo MornatiThis three volume series of intellectual biography considers the life, work and impact on economic, social and political theory of the Italian economist, sociologist and political scientist Vilfredo Pareto (1848-1923).This second volume follows Pareto from his time teaching at Lausanne to the juncture in his life where he first began to make theoretical contributions of his own. Mornati considers Pareto’s work on pure economics, general equilibrium, welfare economics and the economic case for socialism, as well as his critical observations of Italian and Swiss public policy.
Vilfredo Pareto: From Liberty to Science (1898–1923) (Palgrave Studies in the History of Economic Thought)
by Fiorenzo MornatiThis volume of intellectual biography takes the Italian economist, sociologist, political scientist Vilfredo Pareto (1848-1923) from his disillusionment with liberal and pacifist activism, to the original development of pure economics and the composition of his Treatise on General Sociology and the test of this latter on the war and post-war events.
Vilfredo Pareto: From Science to Liberty (1848–1891) (Palgrave Studies in the History of Economic Thought)
by Fiorenzo Mornati Paul WilsonThis three volume series of intellectual biography considers the life, work and impact on economic, social and political theory of the Italian economist, sociologist and political scientist Vilfredo Pareto (1848–1923).This volume covers the period starting from his childhood up to his early political activism, amateur journalism and initial scholarly contributions. His pre-Lausanne years are often neglected by students of Pareto, but form the intellectual and biographical background to his later contributions to economic, social and political theory.
The Village
by Nikita LalwaniIn her award-winning debut novel, Gifted, Nikita Lalwani crafted a brilliant coming-of-age story that "[called] to mind the work of such novelists as Zadie Smith and Monica Ali" (The Washington Post Book World). Now Lalwani turns her gimlet eye on an extraordinary village in India, and explores the thin boundary between morality and evil, innocence and guilt. After a long trip from London, twenty-seven-year-old BBC filmmaker Ray Bhullar arrives at the remote Indian village of Ashwer, which will be the subject of her newest documentary. From the outside, the town projects a cozy air of domesticity--small huts bordering earthen paths, men lounging and drinking tea, women guiding bright cloth through noisy sewing machines. Yet Ashwer is far from traditional. It is an experimental open prison, a village of convicted murderers and their families. As Ray and her crew settle in, they seek to win the trust of Ashwer's residents and administrators: Nandini, a women's counselor and herself an inmate; Jyoti, a prisoner's wife who is raising her children on the grounds; Sujay, the progressive founder and governor of the society. Ray aims to portray Ashwer as a model of tolerance, yet the longer she and her colleagues stay, the more their need for a dramatic story line intensifies. And as Ray's moral judgment competes with her professional obligation, her assignment takes an uneasy and disturbing turn. Incisive, moving, and superbly written, The Village deftly examines the limits of empathy, the slipperiness of reason, and the strength of our principles in the face of personal gain.Praise for The Village "Powerful . . . One of the novel's great strengths is how it maintains an ambience of mystery and menace."--The New York Times Book Review "Extraordinary . . . Lalwani writes with wonderful clarity and intelligence."--The Times (U.K.) "The Village can creep up and grab you unawares."--Toronto Star "[Lalwani's] prose is evocative and excellent."--Publishers Weekly "Thoughtful and beautifully written."--The Guardian (U.K.) "Gripping."--Marie Claire (U.K.)"Intelligent and disturbing . . . a sharply observed, highly personal book."--Pittsburgh Post-Gazette"A thoughtful novel that envelops us in the oppression and beauty of the rural prison . . . Each voice is distinct, believable and stubborn in its refusal to be easily known. . . . Touchingly evocative."--Financial Times "Thoughtfully and often beautifully written . . . a candid exploration of journalistic ethics."--The ObserverFrom the Hardcover edition.rFrom the Hardcover edition.
The Village
by Nikita LalwaniThe long-awaited follow-up to the critically acclaimed, Booker longlisted Gifted, a provocative novel about an experimental open prison in India and the havoc a team of journalists wreaks on the delicate moral code of the inmates. After a long journey from England, Ray Bhullar arrives early on a winter morning at the gates of a remote Indian village called Ashwer which will be her home for the next three months. The door of the hut she will share with Serena, her English co-worker, is a loose sheet of metal, the windows simple holes in the walls. Beyond the lockless door, village life goes on as usual. And yet, the village is anything but normal. Despite the domestic chores being carried out, cooking, fetching water and sewing and laundering linens, Ashwer is a village of murderers, an experimental open prison. And when Ray and her crew take up residence, to observe and to make a documentary, it seems that they are innocent visitors into a violent world, on a mission to hold the place up to viewers as the ultimate example of tolerance. But the longer Ray and her colleagues stay and their need for drama intensifies, the line between innocence and guilt begins to blur and an unexpected and terrifying new kind of cruelty emerges. A mesmerizing and heartfelt tale of manipulation and personal morality, Nikita Lalwani's new novel brilliantly exposes how truly frail our moral judgment can be.